The defendant is charged [in count __]
with the manufacture of bombs. The statute defining this offense reads in
pertinent part as follows:

any person, other than one engaged
in the manufacture of firearms or explosives or incendiary devices for lawful
purposes, who fabricates in any manner, any type of an explosive, incendiary or
other device designed to be dropped, hurled or set in place to be exploded by a
timing device, shall be guilty.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Fabricated
incendiary deviceThe first element is that the
defendant fabricated an explosive, incendiary or other device designed to be
dropped, hurled, or set in place to be exploded by a timing device. The term “explosive
or incendiary device” means (A) dynamite and all other forms of high
explosives, (B) any explosive bomb, grenade, missile or similar device, and (C)
any incendiary bomb or grenade, fire bomb or similar device, including any
device which (i) consists of or includes a breakable container which contains a
flammable liquid or compound and a wick composed of any material which, when
ignited, is capable of igniting such flammable liquid or compound, and (ii) can
be carried or thrown by an individual.

Element 2 - No lawful purposeThe second element is that the
defendant was not engaged in the manufacture of the device for lawful purposes.

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant fabricated <insert type of
device alleged>, and 2) that (he/she) was not engaged in the lawful
manufacture of such devices.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the manufacture of
bombs, then you shall find the defendant guilty. On the other hand, if you
unanimously find that the state has failed to prove beyond a reasonable doubt
any of the elements, you shall then find the defendant not guilty.
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